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FACTS: Judith Gluc sought ERISA-governed long term disability benefits. Prudential paid long term disability benefits for two years, and then discontinued benefits. Gluc then brought suit to recover benefits. She also alleged breach of fiduciary duty and sought disgorgement of “earnings Prudential accumulated as a result of its delay in paying her benefits.”

“[W]here Congress elsewhere provided adequate relief for a beneficiary’s injury, there will likely be no need for further equitable relief, in which case such relief would normally not be ‘appropriate.’” Op. at 4.

“[I]f Section 1132 provides a remedy for Gluc’s alleged injury, her claims for equitable relief are not viable.” Op. at 5.

“Gluc alleges numerous flaws in Prudential’s claims process, but ultimately, the only injury she purports to have suffered is loss of benefits—an injury Section 1132(a)(1)(B) is designed to address.” Op. at 5.

“[T]he ‘accumulated earnings’ Gluc seeks in her disgorgement claim may be recovered through an award of prejudgment interest, which the Court has discretion to make.” Op. at 5.

As to Gluc’s “systemic flaws” allegations, “this is not a class action…[and] she does not allege facts to support a claim of plan-wide wrongdoing. Rather the facts alleged indicate a problem with Prudential’s processing of a single claim.” Op. at 5-6.

Moving to dismiss these claims early can help posture the claim for early, reasonable resolution.

Compare jurisdictions: Arbitration

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